With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also briefly referred to as "data") we process for what purposes and to what extent.
This privacy policy applies to all processing of personal data carried out by us in connection with the use of check-up or screening services. These services are provided for the respective end users, are based on individual consent declarations with them, and are therefore not connected to the data protection agreements concluded with our business partners or employing companies.
The terms used are not gender-specific.
Scope of Data Processing
We generally process personal data of our users only to the extent necessary to provide our content and services. The processing of personal data of our users regularly occurs only with the user's consent. An exception applies in cases where prior obtaining of consent is not possible for factual reasons and the processing of data is permitted by legal regulations.
In the context of our processing of personal data, data may be transmitted to other entities or companies and disclosed to them. In such cases, we observe legal requirements and conclude appropriate agreements to protect your data with the recipients of your data.
Legal Basis for Processing
Where we obtain consent from the data subject for processing operations of personal data, Article 6(1)(a) EU General Data Protection Regulation (GDPR) serves as the legal basis. For the processing of personal data necessary for the performance of a contract to which the data subject is party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations required for the implementation of pre-contractual measures.
Where processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
If processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Article 6(1)(f) GDPR serves as the legal basis for processing.
Storage Duration and Data Deletion
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to exist. Storage may also occur if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. Blocking or deletion of data also occurs when a storage period prescribed by the mentioned norms expires, unless there is a necessity for further storage of the data for concluding or fulfilling a contract.
The following overview summarizes the types of processed data and the purposes of their processing and refers to the affected persons.
4.1. Provision of Health Services
Scope of Data Processing
Health data entered by users is processed to display evaluations of relevant medical parameters and health risks, as well as to inform users about relevant health programs.
The following categories of persons are affected by this data processing:
- End users of "Health Check" services
The following data is collected:
- User profile data (e.g., name, email address, device information, IP address)
- Health data (e.g., weight, blood pressure, blood sugar, pre-existing conditions)
Data transmission occurs to the following recipients outside our organization:
- Amazon Web Services EMEA SARL:
Address: 38 Avenue John F. Kennedy, L-1855 Luxembourg. R.C.S. B186284
Purpose: AWS provides cloud server infrastructure, databases and computing power.
Privacy Policy: https://aws.amazon.com/de/compliance/data-privacy
For Germany: https://aws.amazon.com/de/compliance/germany-data-protection
- Brevo:
Address: Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany
Purpose: Brevo is used for sending login codes and product information.
Privacy Policy: https://www.brevo.com/de/legal/privacypolicy
- MongoDB Ltd:
Address: Building Two, Number One Ballsbridge, Dublin 4, Ireland
Purpose: MongoDB is a database solution for storing and processing data.
Privacy Notice: https://www.mongodb.com/legal/privacy/privacy-policy
Legal Basis and Purpose of Data Processing
The collection and processing of user profile and health data is absolutely necessary to generate health-relevant evaluations and assign them to the respective users. The legal basis for processing personal data for providing Health Checkup services is the existence of relevant user consent according to Article 6(1)(a) GDPR.
Storage Duration and Objection
Data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of collection for providing health services, deletion will be carried out immediately as soon as the user account is closed by the user. Extended storage is possible; in this case, however, remaining data will be completely anonymized so that later assignment to the user is no longer possible.
4.2. Integration of Wearables
Scope of Data Processing
Users can separately consent to allow additional data from the use of wearables (e.g., smartwatch) to be included in the health evaluation.
The following categories of persons are affected by this data processing:
- End users of "Health Check" services
The following data is collected:
- User profile data (e.g., name, email address)
- Health data (e.g., blood pressure, heart rate, step count, sleep duration)
Data transmission occurs to the following recipients outside our organization:
- Thryve Health:
Address: Health Pioneers GmbH, Körtestraße 10, 10967 Berlin, Germany
Purpose: Interface (API) for providing additional health data generated by wearables.
Privacy Policy: https://thryve.health/privacy-policy
Legal Basis and Purpose of Data Processing
The collection and processing of user profile and health data is necessary to generate health-relevant evaluations and assign them to the respective users. For the use of additional wearable data that goes beyond the provision of the basic Health Check-Up, users give separate consent. The legal basis for processing personal data for providing these services is the existence of relevant user consent according to Article 6(1)(a) GDPR.
Storage Duration and Objection
Data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of collection for providing health services, deletion will be carried out immediately as soon as the user account is closed by the user. Extended storage is possible; in this case, however, remaining data will be completely anonymized so that later assignment to the user is no longer possible.
4.3. Scheduling Examination Appointments
Scope of Data Processing
If requested by the organizer, HealthCaters offers users the opportunity to book appointments for health examinations during (corporate) events.
The following categories of persons are affected by this data processing:
- End users of "Health Check" services
The following data is collected:
- User profile data (e.g., name, email address, phone number)
Data transmission occurs to the following recipients outside our organization:
- Acuity Scheduling:
Address: Squarespace Ireland Ltd., Squarespace House, Ship Street Great, Dublin 8, D08N12C, Ireland
Purpose: Acuity Scheduling allows management of calendars and email programs for appointment booking.
Privacy Policy: https://www.squarespace.com/privacy
Legal Basis and Purpose of Data Processing
The collection and processing of this data is necessary to manage appointment bookings for user profiles during events. For the use of this appointment booking service, users give separate consent. The legal basis for processing personal data for providing these services is the existence of relevant user consent according to Article 6(1)(a) GDPR.
Storage Duration and Objection
Data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of data collection for using appointment booking services, deletion will be carried out 12 months after the last booking.
4.4. Ensuring Availability and IT Security
Scope of Data Processing
The processing of additional data is necessary to monitor and ensure the availability and IT security of our IT infrastructure.
The following categories of persons are affected by this data processing:
- End users of "Health Check" services
The following data is collected:
- Meta/communication data (e.g., browser and browser version, operating system and device information, IP address).
- Usage data (e.g., date and time of access, error messages).
Data transmission occurs to the following recipients outside our organization:
- Amazon Web Services EMEA SARL:
Address: 38 Avenue John F. Kennedy, L-1855 Luxembourg. R.C.S. B186284
Purpose: AWS provides cloud server infrastructure, databases and computing power.
Privacy Policy: https://aws.amazon.com/de/compliance/data-privacy
For Germany: https://aws.amazon.com/de/compliance/germany-data-protection
- AppSignal B.V.:
Address: P.O. Box 10212, 1001EE Amsterdam, Netherlands
Purpose: AppSignal is used to monitor and improve the performance and security of web applications.
Privacy Policy: https://www.appsignal.com/privacy-policy
Legal Basis and Purpose of Data Processing
The temporary storage and processing of this data is necessary to enable the provision of services to users. The user's IP address must be stored for approximately the duration of use. Further storage and processing occurs to ensure the functionality of the platform, for the purpose of technical optimization, or to ensure the information technology security of our systems (e.g., to prevent overloads during DDoS attacks). These purposes constitute the legitimate interest according to Article 6(1)(f) GDPR.
Storage Duration and Objection
Data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of collection to ensure performance and IT security, deletion will be automatically carried out after 12 months. Data collected by AppSignal will be automatically deleted after 30 days.
4.5. User Communication and Service Improvement
Scope of Data Processing
The following data is processed to communicate with end users, to obtain user opinions, and to improve the usability of the platform.
The following categories of persons are affected by this data processing:
- End users of "Health Check" services
The following data is collected:
- User profile data (e.g., name, email address, language settings)
- Usage data (e.g., user ID, IP address, browser and browser version, device information)
Data transmission occurs to the following recipients outside our organization:
- Brevo:
Address: Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany
Purpose: Brevo is used for sending login codes and product information.
Privacy Policy: https://www.brevo.com/de/legal/privacypolicy
- TYPEFORM S.L.
Address: c/ Can Rabia 3-5, 4th floor, 08017 Barcelona, Spain
Purpose: Typeform integrates web-based forms of user interaction such as questions and rating scales.
Privacy Policy: https://admin.typeform.com/to/dwk6gt
- Smartlook.com s.r.o.:
Address: Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic
Purpose: Smartlook is an analytics tool used to understand user behavior (e.g., navigation and inputs) in web applications.AWS provides cloud server infrastructure, databases and computing power.
Privacy Policy: https://help.smartlook.com/docs/privacy-policy
Legal Basis and Purpose of Data Processing
The temporary storage and processing of this data serves to obtain user opinions and feedback and is necessary for improving the usability of the application. For example, faulty functions or unused functionalities can be more easily identified and improved. These purposes constitute the legitimate interest according to Article 6(1)(f) GDPR.
Storage Duration and Objection
Data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of collection for service improvement, deletion will be carried out immediately as soon as the user account is closed by the user. Data collected by Smartlook will be automatically deleted after 12 months. Extended storage is possible; in this case, however, remaining data will be completely anonymized so that later assignment to the user is no longer possible.
If personal data concerning you is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller.
Right to Information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing exists, you may request information from the controller about the following:
- The purposes for which the personal data is processed.
- The categories of personal data being processed.
- The recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed.
- The planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage duration.
- The existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing.
- The existence of a right to lodge a complaint with a supervisory authority.
- All available information about the source of the data if the personal data is not collected from the data subject.
- The existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, you have the right to request information about whether the personal data concerning you is transferred to a third country. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 GDPR in connection with the transfer.
Right to Rectification
You have a right to rectification and/or completion if the processed personal data concerning you is inaccurate or incomplete. The controller must make the rectification without delay.
Right to Restriction of Processing
Under the following conditions, you may request the restriction of processing of the personal data concerning you:
- If you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data.
- If the processing is unlawful and you oppose the erasure of the personal data and request instead the restriction of their use.
- If the controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise, or defense of legal claims, or.
- If you have objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.
If processing of the personal data concerning you has been restricted, such data may, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. If the restriction of processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.
Right to Erasure
You may request that the controller delete the personal data concerning you without delay, and the controller is obliged to delete this data without delay, provided that one of the following reasons applies:
The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
- The personal data concerning you has been unlawfully processed.
- The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you has been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
You withdraw your consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.
If the controller has made the personal data concerning you public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you, as the data subject, have requested the erasure of all links to, or copies or replications of, those personal data..
The right to erasure does not apply to the extent that processing is necessary:
- For exercising the right of freedom of expression and information.
- For compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- For reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) as well as Article 9(3) GDPR.
- For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) GDPR, in so far as the right referred to in section (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or.
- For the establishment, exercise, or defense of legal claims.
Right to Notification
If you have exercised the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you have been disclosed, unless this proves to be impossible or involves disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.
Right to Data Portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used, and machine-readable format. Furthermore, you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- The processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR, and.
- The processing is carried out by automated means.
In exercising this right, you furthermore have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. Freedoms and rights of other persons may not be adversely affected thereby. The right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller..
Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR.
The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. If you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
You have the right to revoke your data protection consent declaration at any time. The revocation of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR..
The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes in legal provisions or our data processing activities make this necessary. We will inform you as soon as the changes require a cooperative action on your part or any other individual notification becomes necessary.
